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SCHLOTZSKY’S PRIVACY POLICY

Last Updated: July 1, 2024

Schlotzsky’s Franchisor SPV LLC, Schlotzsky’s Stores LLC, and their affiliates
(collectively, “Schlotzsky’s,” “we,”“our,” “us”) value your privacy. In this
Privacy Policy, we describe how we collect, use, and process the personal
information we obtain about people who use our websites or mobile apps, browse
or purchase our products, apply to become franchisees, or who otherwise interact
with us online or offline (collectively, our “Services”). This Privacy Policy
does not apply to any websites or mobile apps that are created, run, or
controlled by independently owned or operated Schlotzsky’s franchisees or any
other third party.

This Privacy Policy describes our collection, use, and disclosure of personal
information. By downloading, using, creating an account on, or registering for
our Services, or by otherwise providing your personal information to us, you are
agreeing to this Privacy Policy and our Terms and Conditions.

In this Privacy Policy, “personal information” (a/k/a “personal data”) means any
information that Schlotzsky’s processes that identifies, relates to, describes,
is reasonably capable of being associated with, or could reasonably be linked
with a particular person or household.

PERSONAL INFORMATION WE COLLECT ABOUT YOU

We may collect personal information directly from users of our Services. You can
use some parts of our Services without registering or directly submitting your
personal information to us, but we may automatically collect certain information
about your use of our Services through cookies and other tracking technologies.

Information We Collect Directly From You. To use some features of our Services
(for example, to sign up for rewards programs, enter contests, make a purchase,
or request a franchise kit from us), you must register with us or otherwise
provide us with your personal information. We also may collect personal
information that you enter through our Services or provide to us in other ways,
such as through email or text message. The types of personal information that we
collect from you will depend on your interactions with us and how you use our
Services, but may include:

 * personal details, such as full name, mailing address, email address, phone
   number, and other contact information;
 * purchase transaction information, such as information about the products you
   buy, billing address, method of payment, and payment details;
 * location data; and
 * other personal information you choose to provide to us.


Information We Collect Automatically. We, and the vendors we work with, may also
collect other information about your use of our Services using automated tools.
For example, cookies and other passive information collection technologies
enable us to compile aggregate statistics concerning use of our Services,
analyze trends, enhance the security of our Services, deliver content and
advertisements, and otherwise administer and improve our Services. This
information may include your browser type, language preference, operating
system, device identifier, device type, access time, Internet Protocol (IP)
address, the URLs of websites you visited before and after visiting our
websites, the web search that landed you on our websites, the length of your
visits to our websites, and the links you click and pages you visit within our
websites. You can set your browser not to accept cookies, to remove cookies, or
to notify you when you are sent a cookie, giving you the opportunity to decide
whether or not to accept it. However, please note that if you disable the use of
cookies on your computer, some functionality of our websites will not work.

Your web browser may have settings that allow you to transmit a “Do Not Track”
signal when you visit various websites or use online services. Like many
websites, our websites are not designed to respond to “Do Not Track” signals
received from browsers.

We may use certain third-party web analytics services to help us understand and
analyze how visitors use our Services and to serve advertisements on our behalf
across the Internet. We have implemented Google Analytics Advertising features
such as dynamic remarketing, interest-based advertising, audience targeting,
behavioral reporting, demographics and interests reporting, user segment
analysis, device reporting, display advertising, and video ads reporting. We may
use cookies and other identifiers to deliver advertisements, create a profile of
you, measure your interests, personalize content, and detect your demographics,
location, or device. For more information on how Google Analytics uses data,
visit www.google.com/policies/privacy/partners/. To opt out of Google Analytics
and advertising cookies, visit myadcenter.google.com and
tools.google.com/dlpage/gaoptout/.

We use Hotjar, a service provider, to help us understand and analyze how
visitors use our services, and to improve the services. Hotjar may collect the
following types of information from users of our websites:

 * device IP Address
 * device screen size
 * device type (unique device identifiers)
 * browser information, geographic location (country only)
 * preferred language used to display our website


Hotjar stores the above information in a pseudonymized format. Hotjar does not
use this information to identify individual users, or match or link the
information with other information about users. Hotjar is contractually
forbidden to sell any of the data collected on our behalf. For more information
regarding Hotjar's collection and use of information, please visit Hotjar's
privacy policy here.

Information We Collect About Your Location. Our Services may access and collect
your geolocation information to facilitate our provision of Services, such as to
provide you with information about stores near you. We also may use information
about the location of the device you are using to help us understand how our
Services are being used and to deliver more relevant advertising. For most
mobile devices and computer systems, you are able to withdraw your permission
for us to collect this information through your device or web-browser settings.

Information We Collect From Others. We may collect personal information about
customers, prospective franchisees, and current franchisees from our affiliated
companies, franchisees, service providers, and third parties. We also may
collect information about any comments or reviews you post about us on third-
party websites. When submitting information to a third party, you are subject to
that third party’s terms of use and privacy policies. Schlotzsky’s may combine
information about you that we already have with information we obtain from third
parties. If you submit someone else’s personal information to us, you represent
that you have been authorized to provide this information to us.

HOW WE USE YOUR INFORMATION

We may use your personal information to:

 * communicate with you, including to respond to your questions and requests,
   provide you with documentation or communications you have requested, send you
   notices about our Services, offer customer support, or contact you for
   information or after-sales support;
 * process your orders or purchases;
 * market and advertise our products, including to send you news, updates,
   special offers and promotions, and targeted advertising;
 * personalize our content, including to make recommendations to you about our
   Services, to tailor the information we send or show you, and to offer
   location-based customizations and personalization based on your purchase
   history or past interactions with our Services;
 * monitor and analyze trends, usage, and the activities of users of our
   Services to better understand how our users access and use our Services in
   order to improve them, respond to user preferences, and for other research
   purposes;
 * improve our Services and notify you about important updates;
 * perform business analyses or for other business purposes, such as evaluating
   transactions and involving our Services;
 * facilitate, manage, personalize, and improve our partnership and franchisee
   relationships;
 * identify, prevent, investigate, and take other actions with respect to
   suspected or actual fraud or illegal activity or other activity that violates
   our policies;
 * ensure the security and integrity of our personal information processing;
 * protect our rights, property, or safety and that of our users and our
   confidential and proprietary information;
 * comply with applicable laws, rules, regulations, and legal processes as well
   as our company policies, including to respond to claims asserted against us
   and to enforce or administer terms and agreements; and
 * achieve other purposes, with your consent (when required).


HOW WE DISCLOSE YOUR INFORMATION

We may disclose your personal information within our company, with our
affiliates, with our business partners and franchisees, and with our vendors. We
also may disclose your personal information to:

 * provide you with products or services, such as when we use a payment
   processor or app developer;
 * better respond to your inquiries;
 * advertise or market our products and services;
 * perform marketing research and for sales, support, and service-related
   purposes;
 * protect rights, property, life, health, security, and safety;
 * respond to legal process, including to disclose personal information to a
   court, legal authority, opposing party in litigation, our legal counsel, or
   other advisors in connection with a judicial proceeding, court order,
   subpoena, or other legal process;
 * negotiate or complete any proposed or actual merger, purchase, sale, or any
   other type of acquisition or other transaction, including a transfer of all
   or a portion of our business to another organization;
 * disclose personal information with your consent or at your direction; and
 * achieve any other purpose consistent with our statements in this Privacy
   Policy or otherwise allowed by applicable law.


We may disclose your personal information to comply with applicable law, such as
in response to requests from law enforcement agencies, regulators, other public
authorities, courts, and third-party litigants in connection with legal
proceedings or investigations.

Any information, including personal information, that you post on any public
areas of our Services, such as reviews, comments, and photos, may be available
to, and searchable by, all other users. Reviews also may be publicly accessible.

LINKS TO OTHER WEBSITES

Our Services include links to websites operated by our service providers that
are designed to provide specific features or content (for example, sites
supporting online orders or gift card purchases), and may also include links to
third-party websites. Third-party websites have their own privacy policies that
you should review to understand how they may collect, use, or disclose your
personal information. We are not responsible for the content or privacy
practices of any linked websites that are not under our control.

SOCIAL FEATURES

Certain features of our Services may permit you to interact with social media
networks operated by unaffiliated parties, for example, if you “like” or
“follow” us on those platforms (“Social Features”). If you choose to “like” or
share content or post information using Social Features, that information may be
publicly displayed, and the party operating the social media platform may
receive information about you and your use of our Services. Similarly, if you
interact with us through Social Features, we may have access to information
about you from the social media platform. In addition, we may track when you
like us, follow us, or share our content through Facebook, Twitter, or other
social media platforms.

Please note that if you mention Schlotzsky’s, or comment about or in response to
us, in your post on a social media platform, that platform may allow us to
publish your post on our Services or public social media pages or otherwise use
your post about us. You should review the terms, policies, and settings of these
platforms to learn more about their data practices and adjust your settings
accordingly.

USER-GENERATED CONTENT

Any content you post to our Services or public social media pages
(“User-Generated Content”) may be visible to and searchable by all users or the
general public, and we may not be able to prevent such content from being used
in a manner that violates this Privacy Policy, the law, or your personal
privacy. For instance, third parties may have republished your User-Generated
Content, or it may have been archived Page 5 of 2 by search engines and others
that we cannot control. We may revise such User-Generated Content, remove it, or
combine your User-Generated Content with other information we have collected
about you and use it as described in this Privacy Policy. All User-Generated
Content is subject to our Terms and Conditions.

In addition, we may collect information from you when you contact us or when you
submit a review, comment, or other content to our Services or on our social
media pages. We may choose to disclose the personal testimonials of our
customers, including your name, on our Services or with our affiliates, our
business partners and franchisees, and our vendors. If you wish to update or
delete your testimonial, you can contact us at privacy@schlotzskys.com.

SECURITY OF YOUR PERSONAL INFORMATION

At no cost to you, we maintain appropriate safeguards designed to protect
personal information from loss, theft, misuse, and unauthorized access,
disclosure, alteration, and destruction. Nevertheless, no data security measures
can guarantee 100% security. We encourage you to safeguard your passwords, ID
numbers, and other information you use to access our Services.

OUR RETENTION OF YOUR PERSONAL INFORMATION

We retain personal information for as long as necessary or permitted for the
purposes described in this Policy or otherwise authorized by law. This generally
means holding the information for as long as one of the following apply:

 * your personal information is reasonably necessary to manage our operations,
   to manage your relationship with us, or to satisfy another purpose for which
   we collected the information;
 * your personal information is reasonably necessary to carry out a disclosed
   purpose that is reasonably compatible with the context in which the personal
   information was collected;
 * the personal information is reasonably necessary to protect or defend our
   rights or property (which will generally relate to applicable laws that limit
   actions in a particular case); or
 * we are otherwise required or permitted to keep your personal information by
   applicable laws or regulations.

Where personal information is used for more than one purpose, we will retain it
until the purpose with the latest period expires. For more information about our
retention practices, please contact us using the contact details below.

YOUR CHOICES

Updating Your Information. If you wish to update the personal information you
have provided to us, you may do so by logging in to your account or by
contacting us through our Contact Us form. Please note that outdated copies of
information that you have updated may remain viewable in cached and archived
pages for a period of time, and we may maintain records in our systems of this
information as well.

Marketing Emails. You may opt out of marketing email communications by following
the opt-out instructions contained in any email you receive from us or by
submitting your request here . Please note that it may take up to ten (10)
business days for us to process opt-out requests. If you opt out of marketing
email communications, we may still send you administrative emails about your
account or any product you have requested or received from us.

Text Messages. ou have the choice to opt-in to receiving text messages and
alerts on the mobile phone number(s) you disclose to us. Once you opt-in, we may
send you text messages (i) regarding your account and your orders; (ii) about
our products and promotions (including advertisements, sales, and special
offers); (iii) to investigate or prevent fraud; and (iv) to alert you in the
event of an issue with any of your purchases. You do not have to opt-in to text
messages and alerts to use and enjoy our websites or products. If you opt-in,
standard text messaging charges may apply. You may choose to opt-out of our text
messages and alerts at any time by sending us a text message from your mobile
phone with the word STOP, STOP ALL, END, QUIT, CANCEL or UNSUBSCRIBE, and we
will unsubscribe you from text communications.

Mobile App. If you no longer wish to provide us with information through one of
our mobile apps, you may delete or deactivate your account through the app or
our website. Please see our Terms and Conditions for instructions.

PRIVACY OF CHILDREN

Our Services are not intended for children, and we do not knowingly collect
personal information from children. If we become aware that we have collected
personal information from a child, we will delete it in accordance with
applicable law.

ADDITIONAL INFORMATION FOR FRANCHISEES

If you submit your personal information to request more information from us
about our franchise opportunities, we may use that information to contact you to
discuss our franchise opportunities. We may ask that you complete our franchise
application, which requests the following additional types of personal
information from you, including:

 * franchise ownership details and history;
 * financial information, including details of current assets and liabilities,
   annual income, investments, mortgages, insurance, ACH information, and any
   history of bankruptcy;
 * driver’s license, state ID, social security, and passport numbers;
 * criminal history (if any).


We may disclose the information provided in our franchise application with our
affiliated brands and vendors as needed to process your franchise application,
including to run background checks and to determine creditworthiness.

If you provide personal information related to other people, such as your
spouse, investment partners, or personal references, as part of the franchise
application process, you guarantee that you do so with the knowledge and
permission of those people. We may use any information you provide to contact
those people and disclose it, as necessary, with our affiliated brands and
vendors during the franchise application process.

SUPPLEMENTAL NOTICE FOR RESIDENTS OF COVERED U.S. STATES

As a supplement to the other information provided throughout this Privacy
Policy, we provide the following additional information as a notice to consumers
in Colorado, Oregon, and Texas.

How and Why We Collect Personal Information.

CATEGORY OF PERSONAL INFORMATION CATEGORIES OF SOURCES PURPOSES FOR COLLECTION
Identifiers, including name, alias, postal address, unique personal identifier,
online identifier, Internet Protocol (IP) address, email address, account name,
or other similar identifiers Directly from you

Automatically when you use our Services

Advertising networks

Internet service providers

Data analytics providers

Social networks

Vendors that help us to fulfill and deliver orders, process payments, support
our promotions, contests, gift cards, loyalty programs, and sweepstakes, and
provide communications, marketing or other services on our behalf

Our affiliated brands and companies

Franchisees

Data brokers Processing your purchases of or requests for products or services

Communicating with you

To support our contests, promotions, loyalty programs, coupons, and sweepstakes

Customer service

Marketing and advertising

To better understand how users access and use the Services, to improve the
Services, to respond to user desires and preferences, and for other research and
analytical purposes

To help maintain the safety, security, and integrity of our Services, databases
and other technology assets, as well as your account, orders, and deliveries

Detecting, investigating, or protecting against malicious, deceptive, fraudulent
or illegal activity

Tailoring our content or otherwise personalizing the Services Personal records,
including name, signature, physical characteristics or description, address,
telephone number, employment, credit or debit card number, other financial
information (including gift cards) Directly from you

Automatically when you use our Services

Advertising networks

Internet service providers

Data analytics providers

Social networks

Vendors that help us to fulfill and deliver orders, process payments, support
our promotions, contests, gift cards, loyalty programs, and sweepstakes, and
provide communications, marketing or other services on our behalf

Our affiliated brands and companies

Franchisees

Data brokers Processing your purchases of or requests for products or services

Communicating with you

Supporting our contests, promotions, loyalty programs, coupons, and sweepstakes

Customer service

Marketing and advertising

To better understand how users access and use the Services, to improve the
Services, to respond to user desires and preferences, and for other research and
analytical purposes

To help maintain the safety, security, and integrity of our Services, databases
and other technology assets, as well as your account, orders, and deliveries

Detecting, investigating, or protecting against malicious, deceptive, fraudulent
or illegal activity

Tailoring our content or otherwise personalizing the Services Characteristics of
protected classifications, including gender, age, and date of birth Directly
from you

Our affiliated brands and companies

Data analytics providers

Data brokers Communicating with you

To support our contests, promotions, loyalty programs, coupons, and sweepstakes

Marketing and advertising

To better understand how users access and use the Services, to improve the
Services, to respond to user desires and preferences, and for other research and
analytical purposes

Customer service

To help maintain the safety, security, and integrity of our Services, databases
and other technology assets, as well as your account, orders, and deliveries

Detecting, investigating, or protecting against malicious, deceptive, fraudulent
or illegal activity Commercial information, including records of products or
services purchased, obtained, or considered, or other purchasing or consuming
histories or tendencies Directly from you

Automatically when you use our Services

Advertising networks

Data analytics providers

Social networks

Vendors that help us to fulfill and deliver orders, process payments, support
our promotions, contests, gift cards, loyalty programs, and sweepstakes, and
provide communications, marketing or other services on our behalf

Our affiliated brands and companies

Franchisees
Data brokers Processing your purchases of or requests for products or services

Communicating with you

Supporting our contests, promotions, loyalty programs, coupons, and sweepstakes

Customer service

Marketing and advertising

Tailoring our content or otherwise personalizing the Services

Detecting, investigating, or protecting against malicious, deceptive, fraudulent
or illegal activity Internet or other electronic network activity information,
including browsing history, search history, and information regarding
interactions with our websites, applications, or advertisements Directly from
you

Automatically when you use our Services

Advertising networks

Internet service providers

Data analytics providers

Social networks

Franchisees

Vendors that help us to fulfill and deliver orders, process payments, support
our promotions, contests, gift cards, loyalty programs, and sweepstakes, and
provide communications, marketing or other services on our behalf To better
understand how users access and use the Services, to improve the Services, to
respond to user desires and preferences, and for other research and analytical
purposes

To help maintain the safety, security, and integrity of our Services, databases
and other technology assets, as well as your account, orders, and deliveries

Detecting, investigating, or protecting against malicious, deceptive, fraudulent
or illegal activity

Marketing and advertising

Tailoring our content or otherwise personalizing the Services
Customer service Geolocation data, including the location of the consumer
inferred from IP address or mobile app usage Automatically when you use our
Services

Advertising networks

Internet service providers

Data analytics providers

Social networks

Vendors that help us to fulfill and deliver orders, and provide communications,
marketing or other services on our behalf Processing your purchases of or
requests for products or services

Customer service

Marketing and advertising

To better understand how users access and use the Services, to improve the
Services, to respond to user desires and preferences, and for other research and
analytical purposes

To help maintain the safety, security, and integrity of our Services, databases
and other technology assets, as well as your account, orders, and deliveries

Detecting, investigating, or protecting against malicious, deceptive, fraudulent
or illegal activity

Tailoring our content or otherwise personalizing the Services Audio, electronic,
visual, thermal, olfactory, or similar information, including recorded phone
calls and in-store video surveillance Directly from you

Automatically when you use our Services. For example, if you interact with us by
phone or video

Franchisees Processing your purchases of or requests for products or services

Customer service

To better understand how users access and use the Services, to improve the
Services, to respond to user desires and preferences, and for other research and
analytical purposes

To help maintain the safety, security, and integrity of our Services, databases
and other technology assets, as well as your account, orders, and deliveries

Detecting, investigating, or protecting against malicious, deceptive, fraudulent
or illegal activity Professional or employment-related information Directly from
you Supporting our contests, promotions, loyalty programs, coupons, and
sweepstakes

Detecting, investigating, or protecting against malicious, deceptive, fraudulent
or illegal activity Inferences reflecting a person’s preferences,
characteristics, psychological trends, predispositions, behavior, attitudes,
intelligence, abilities, aptitudes Inferred from other categories of personal
information we collect

Data analytics providers

Our affiliated brands and companies To better understand how users access and
use the Services, to improve the Services, to respond to user desires and
preferences, and for other research and analytical purposes

Tailoring our content or otherwise personalizing the Services

Marketing and advertising

Detecting, investigating, or protecting against malicious, deceptive, fraudulent
or illegal activity

In addition to the purposes described above, we may use and disclose any
category of personal information we collect to comply with law, cooperate with
and respond to law enforcement requests, or as otherwise required by applicable
law, court order, or governmental regulations; to maintain appropriate records
for internal administrative purposes; to protect our rights and interests and
those of our franchisees, to resolve any disputes, to enforce this Policy or any
of our other policies, to protect the rights or property of another, or to
prevent harm; and to evaluate or conduct a merger, sale, or other acquisition of
some or all of our organization or its assets.

Disclosure of Personal Information. The following charts summarize how we
disclose personal information. Although we do not sell personal information in
exchange for money, some of the ways in which we share personal information for
advertising or disclose personal information to our affiliated brands and
franchisees may be considered “sales” under some state privacy laws.

The first chart below shows the categories of personal information that we share
for purposes of targeted advertising or otherwise “sell” for non-monetary
consideration. The second chart describes the categories of personal information
we disclose for a business or commercial purpose.

Sales and Sharing of Personal Information

CATEGORY OF PERSONAL INFORMATION CATEGORIES OF THIRD PARTIES TO WHICH SOLD OR
SHARED PURPOSES FOR SELLING / SHARING Identifier Our affiliated brands and
companies

Franchisees

Advertising partners and social media platforms
Analytics, data strategy, consultation on, development or improvement of
products and services, marketing, advertising, and related services for the
benefit of Focus Brands and its affiliated companies, brands, and franchisees

Co-marketing, targeted advertising, remarketing, and customized advertising
content Personal records Our affiliated brands and companies

Franchisees

Advertising partners and social media platforms Analytics, data strategy,
consultation on, development or improvement of products and services, marketing,
advertising, and related services for the benefit of Focus Brands and its
affiliated companies, brands, and franchisees

Co-marketing, targeted advertising, remarketing, and customized advertising
content Characteristics of protected classifications Our affiliated brands and
companies

Franchisees

Advertising partners and social media platforms Analytics, data strategy,
consultation on, development or improvement of products and services, marketing,
advertising, and related services for the benefit of Focus Brands and its
affiliated companies, brands, and franchisees

Co-marketing, targeted advertising, remarketing, and customized advertising
content Commercial information Our affiliated brands and companies

Franchisees

Advertising partners and social media platforms Analytics, data strategy,
consultation on, development or improvement of products and services, marketing,
advertising, and related services for the benefit of Focus Brands and its
affiliated companies, brands, and franchisees

Co-marketing, targeted advertising, remarketing, and customized advertising
content Internet or other electronic network activity information Our affiliated
brands and companies

Advertising partners and social media platforms Analytics, data strategy,
consultation on, development or improvement of products and services, marketing,
advertising, and related services for the benefit of Focus Brands and its
affiliated companies, brands, and franchisees

Co-marketing, targeted advertising, remarketing, and customized advertising
content Geolocation Data Our affiliated brands and companies

Advertising partners and social media platforms Analytics, data strategy,
consultation on, development or improvement of products and services, marketing,
advertising, and related services for the benefit of Focus Brands and its
affiliated companies, brands, and franchisees

Co-marketing, targeted advertising, remarketing, and customized advertising
content Inferences Our affiliated brands and companies

Franchisees Analytics, data strategy, consultation on, development or
improvement of products and services, marketing, advertising, and related
services for the benefit of Focus Brands and its affiliated companies, brands,
and franchisees

Co-marketing, targeted advertising, remarketing, and customized advertising
content


Disclosures for a Business or Commercial Purpose

CATEGORY OF PERSONAL INFORMATION CATEGORIES OF RECIPIENTS PURPOSES FOR
DISCLOSURE Identifier Franchisees

Our affiliated brands and companies

Service providers that we use to support our business and operations

Professional advisors, external auditors, and government bodies Processing your
purchases of or requests for products or services

Performing services on our behalf (e.g., fulfilling and delivering orders,
processing payments, supporting our promotions, contests, gift cards, loyalty
programs, and sweepstakes, and providing communications, technical, analytical,
web hosting, cloud hosting and mobile application support, or other services on
our behalf)

As part of the support we provide to franchisees

Providing advertising and marketing services

Short-term, transient use, including, but not limited to, non-personalized
advertising

Auditing, related to ad impressions

Ensuring security and integrity of personal information

Debugging to identify and repair errors that impair existing intended
functionality

Detecting, investigating, or protecting against malicious, deceptive, fraudulent
or illegal activity Personal records Franchisees

Our affiliated brands and companies

Service providers that we use to support our business and operations

Professional advisors, external auditors, and government bodies Processing your
purchases of or requests for products or services

Performing services on our behalf (e.g., fulfilling and delivering orders,
processing payments, supporting our promotions, contests, gift cards, loyalty
programs, and sweepstakes, and providing communications, technical, analytical,
web hosting, cloud hosting and mobile application support, or other services on
our behalf)

As part of the support we provide to franchisees

Providing advertising and marketing services

Short-term, transient use, including, but not limited to, non-personalized
advertising

Auditing, related to ad impressions

Ensuring security and integrity of personal information

Debugging to identify and repair errors that impair existing intended
functionality

Detecting, investigating, or protecting against malicious, deceptive, fraudulent
or illegal activity Characteristics of protected classifications Franchisees

Our affiliated brands and companies

Service providers that we use to support our business and operations

Professional advisors, external auditors, and government bodies Performing
services on our behalf (e.g., fulfilling and delivering orders, processing
payments, supporting our promotions, contests, gift cards, loyalty programs, and
sweepstakes, and providing communications, technical, analytical, web hosting,
cloud hosting and mobile application support, or other services on our behalf)

As part of the support we provide to franchisees

Providing advertising and marketing services

Short-term, transient use, including, but not limited to, non-personalized
advertising

Detecting, investigating, or protecting against malicious, deceptive, fraudulent
or illegal activity Commercial information Franchisees

Our affiliated brands and companies

Service providers that we use to support our business and operations

Professional advisors, external auditors, and government bodies Processing your
purchases of or requests for products or services

Performing services on our behalf (e.g., fulfilling and delivering orders,
processing payments, supporting our promotions, contests, gift cards, loyalty
programs, and sweepstakes, and providing communications, technical, analytical,
web hosting, cloud hosting and mobile application support, or other services on
our behalf)

As part of the support we provide to franchisees

Providing advertising and marketing services

Short-term, transient use, including, but not limited to, non-personalized
advertising

Auditing, related to ad impressions

Ensuring security and integrity of personal information

Debugging to identify and repair errors that impair existing intended
functionality

Detecting, investigating, or protecting against malicious, deceptive, fraudulent
or illegal activity Internet or other electronic network activity information
Our affiliated brands and companies

Service providers that we use to support our business and operations

Professional advisors, external auditors, and government bodies Processing your
purchases of or requests for products or services

Performing services on our behalf (e.g., fulfilling and delivering orders,
processing payments, supporting our promotions, contests, gift cards, loyalty
programs, and sweepstakes, and providing communications, technical, analytical,
web hosting, cloud hosting and mobile application support, or other services on
our behalf)

Providing advertising and marketing services

Short-term, transient use, including, but not limited to, non-personalized
advertising

Auditing, related to ad impressions

Ensuring security and integrity of personal information

Debugging to identify and repair errors that impair existing intended
functionality

Detecting, investigating, or protecting against malicious, deceptive, fraudulent
or illegal activity Geolocation Data Our affiliated brands and companies

Service providers that we use to support our business and operations

Professional advisors, external auditors, and government bodies Processing your
purchases of or requests for products or services

Performing services on our behalf (e.g., fulfilling and delivering orders,
processing payments, supporting our promotions, contests, gift cards, loyalty
programs, and sweepstakes, and providing communications, technical, analytical,
web hosting, cloud hosting and mobile application support, or other services on
our behalf)

Providing advertising and marketing services

Short-term, transient use, including, but not limited to, non-personalized
advertising

Auditing, related to ad impressions

Ensuring security and integrity of personal information

Debugging to identify and repair errors that impair existing intended
functionality

Detecting, investigating, or protecting against malicious, deceptive, fraudulent
or illegal activity Audio, electronic, visual, thermal, olfactory, or similar
information Our affiliated brands and companies

Service providers that we use to support our business and operations

Professional advisors, external auditors, and government bodies Performing
services on our behalf (e.g., providing communications, technical, analytical,
web hosting, cloud hosting and mobile application support, or other services on
our behalf)

Debugging to identify and repair errors that impair existing intended
functionality

Detecting, investigating, or protecting against malicious, deceptive, fraudulent
or illegal activity Professional or employment-related information Our
affiliated brands and companies

Service providers that we use to support our business and operations

Professional advisors, external auditors, and government bodies Performing
services on our behalf (e.g., supporting our promotions, contests, gift cards,
loyalty programs, and sweepstakes, or other services on our behalf)

Detecting, investigating, or protecting against malicious, deceptive, fraudulent
or illegal activity Inferences Our affiliated brands and companies

Service providers that we use to support our business and operations

Professional advisors, external auditors, and government bodies Performing
services on our behalf (e.g., providing communications, technical, analytical,
web hosting, cloud hosting and mobile application support, or other services on
our behalf)

Providing advertising and marketing services

Auditing, related to ad impressions

Ensuring security and integrity of personal information

Detecting, investigating, or protecting against malicious, deceptive, fraudulent
or illegal activity


Privacy Rights for Consumers in Covered States

If you are a consumer who lives in Colorado, Oregon or Texas, you have the right
to submit certain requests relating to your personal information as described
below. To exercise your rights, please submit a request through our webform or
email us at privacy@schlotzskys.com. To opt out of targeted advertising, go to
the Your Privacy Choices link in the cookie banner or the footer of the website
where you want to opt out. Please note that we may need to authenticate your
identity before your request can be processed. For authentication, you will be
asked to log into your account or to provide 2-3 pieces of personal information
that we will match against our records.

Right to Access and Data Portability. You have the right to confirm whether we
are processing your personal information, to access your personal information,
and to obtain a copy of personal information you provided to us in a portable
format. Oregon consumers may also request a list of third parties to which we
disclosed personal information.

Right to Correct. You have the right to request that we correct inaccuracies in
your personal information, taking into account the nature of the personal
information and our purposes for processing it.

Right to Delete. You have the right to request that we delete your personal
information, subject to exceptions.

Right to Opt Out. You have the right to opt out of the following uses of your
personal information: (i) targeted advertising; (ii) the sale of personal
information; and (iii) profiling in furtherance of decisions that produce legal
or similarly significant effects concerning your economic situation, health,
personal preferences, interests, reliability, behavior, location, or movements.
We do not sell personal information in exchange for money or engage in practices
that qualify as profiling producing legal or similarly significant effects under
applicable state privacy laws. To opt out of targeted advertising and/or non-
monetary “sales” of personal information, please submit a request as outlined
above. If you choose to use a browser-based opt-out signal, such as the Global
Privacy Control, you will be opted out of cookie- based sales or sharing of
personal information and will need to turn it on for each browser you use. If
you are an authorized agent submitting an opt-out request on behalf of a
consumer where allowed by law, please follow the instructions provided above and
within our webform. We use commercially reasonable efforts to authenticate the
identity of the consumer to whom the request relates and the authorized agent’s
authority to act on the consumer’s behalf.

Right to Appeal. Sometimes we are unable to process requests relating to your
personal information, in which case, your request will be denied. If your
privacy rights request has previously been denied by us and you believe we
denied it in error, you may appeal for reconsideration of your request using our
webform.

Please note that if you make a privacy rights request, we will retain a record
of your request for recordkeeping purposes.

Loyalty Program Disclosures for Colorado Residents

The purpose of this section is to notify Colorado consumers about how we use
personal information in connection with our Rewards program. You have the right
to delete your personal information associated with your Rewards account;
however, if you delete your personal information, we will be unable to link your
rewards to your account, and therefore you will be unable to receive benefits
from the program.

The chart below identifies the categories of personal information collected
through our Rewards program that we sell or process for targeted advertising,
and the third parties who receive these categories of personal information.

Categories of Personal Information Third Parties Identifiers

Personal records

Gender

Commercial information/purchase records

Inferences Advertising Partners

Franchisees

Loyalty Program Partners as described below


The chart below identifies our loyalty program partners, and the program
benefits provided by each partner.


Loyalty Program Partner Benefits Provided Schlotzsky’s Franchisees
Points, discounts, and other rewards associated with our rewards program
Partner Businesses Enhanced or additional rewards or discounts AARP Enhanced or
additional rewards or discounts for AARP members

For more information about how we process your personal information, please
click here.

ADDITIONAL INFORMATION FOR NEVADA RESIDENTS

Nevada law provides residents the right to opt out of the “sale” of “covered
information” to third parties, including but not limited to name, address,
social security number, telephone number, email address, and other information
through which a person may be contacted. Our uses of your personal information
are not sales under Nevada law. If you have any questions or if you would like
to receive notice by email in the event we should engage in “sales” of personal
information under Nevada law in the future, please contact us using the contact
information provided below.

INTERNATIONAL USERS

Schlotzsky’s is based in the United States. If you are using our Services
outside the United States, please be aware that personal information we obtain
about you may be transferred to and processed in the United States or other
jurisdictions outside your own. Your personal information may be accessible by
public authorities where it is processed. By using our Services and providing
your personal information, you acknowledge that your personal information may be
transferred to and processed in jurisdictions other than your own. Please be
aware that the data protection laws and regulations that may apply to your
personal information transferred to the United States or other countries may be
different from the laws in your country of residence.

NOTICE TO EUROPEAN ECONOMIC AREA AND UNITED KINGDOM RESIDENTS

As a supplement to the information provided throughout this Privacy Policy, we
provide the following information as a notice to residents of the European
Economic Area (“EEA”) of their rights under the European Union’s General Data
Protection Regulation and residents of the United Kingdom (“UK”) of their rights
under the United Kingdom’s General Data Protection Regulation.

Schlotzsky’s Stores LLC is the data controller for customer personal information
collected through our Services. Schlotzsky’s Franchisor SPV LLC is the data
controller with respect to the data of franchisees, prospective franchisees, and
franchisee applicants it collects or otherwise processes. You may be required to
provide certain personal information, such as your contact information and
payment details, in order to use our Services and place an order for our
products.

Legal Bases for Our Personal Information Processing. Your personal information
is processed under the following legal bases:

 * The processing is necessary for us to provide you with the services you
   request or to respond to your questions.
 * We have a legal obligation to process your personal information, such as
   compliance with applicable tax laws or other government regulations or
   compliance with a court order or binding law enforcement request.
 * We have a legitimate interest in processing your personal information and our
   reasons for using your personal information outweigh the potential prejudice
   to your data protection rights. In particular, we have a legitimate interest
   in the following instances:
    * To analyze and improve the safety and security of our Services, including
      by implementing and enhancing security measures and safeguards and
      protecting against fraud, spam, and other abuses;
    * To maintain and improve our Services;
    * To operate and promote our Services, to advertise and provide you with
      information and communications about our Services that are tailored to,
      and in accordance with, your preferences; and
    * To protect our legal rights, prevent misuse of our Services, perform on a
      contract, or comply with other legal obligations.

 * You have consented to our processing of your personal information. When you
   consent, you may change your mind and withdraw your consent at any time by
   emailing us at privacy@schlotzskys.com.


Your Privacy Rights. You may ask us to take the following actions with respect
to your personal information:

 * provide you with information about our processing of your personal
   information and access to your personal information;
 * update or correct inaccuracies in your personal information;
 * delete your personal information;
 * transfer a copy of your personal information to you or a third party of your
   choice; and
 * stop or restrict our processing of your personal information.

You may submit these requests by emailing us at privacy@schlotzskys.com. We may
require specific information from you to help us verify your identity prior to
processing your request. Applicable law may require or permit us to decline your
request. If we decline your request, we will tell you why, subject to any legal
restrictions on disclosing this information.

Submitting a Complaint. If you would like to submit a complaint about our use of
your personal information or our response to your request regarding your
personal information, you may contact us at privacy@schlotzskys.com or submit a
complaint directly to the data protection authority in your jurisdiction. If you
reside in the EEA, you can find information about your data protection authority
here. If you reside in the UK, you may file complaints with the Information
Commissioner’s Office here.

Transfers of Your Personal Information. WWhen you directly provide your personal
information through our Services, you acknowledge that your personal information
is being provided by you to a company based in the United States. The laws that
apply to personal information protection in the United States differ from those
applicable in the EEA and the UK. If it is necessary for us to transfer personal
information out of the EEA and the UK, we do so by using suitable data transfer
safeguards, such as the standard contractual clauses approved by the European
Commission, which impose data protection obligations on parties to the transfer.
You may obtain additional information about our data transfer mechanisms by
contacting us at privacy@schlotzskys.com.

NOTICE TO RESIDENTS OF CANADA

Your Privacy Rights. You have the following rights with respect to your personal
information:

 * access to your personal information;
 * verify or correct inaccuracies in your personal information;
 * delete your personal information; and
 * where you have provided your consent to the collection, use, transfer, or
   other processing of your personal information, withdraw your consent under
   certain circumstances.


You may submit these requests by email to us at privacy@schlotzskys.com. We may
require specific information from you to help us verify your identity prior to
processing your request. Applicable law may require or permit us to decline your
request. If we decline your request, we will tell you why, subject to any legal
or regulatory restrictions on disclosing this information. Please note, if you
withdraw your consent, we may not be able to provide you with a particular
product or service. We will explain any impact to you to help you with your
decision.

CHANGES TO THIS POLICY

We may update or modify this Privacy Policy from time to time at our discretion.
We will indicate changes to this Privacy Policy by updating the “Last Updated”
date at the beginning of the Privacy Policy. Please review this Privacy Policy
periodically and especially before you provide any personal information to us.
Your continued use of our Services after any update will constitute your
acceptance of our changes.

CONTACT US

If you have questions about this Privacy Policy or Schlotzsky’s privacy
practices, please contact us at privacy@schlotzskys.com or by mail at 5620
Glenridge Drive NE, Atlanta, GA 30342.


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